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transforming global foreign exchange markets

e-FOREX

e-forex.net MAY 2025

CELEBRATING 25 YEARS OF PUBLICATION

ECNs:

Offering flexible, transparent and

efficient solutions for FX execution

OMSs:

Exploring how FX trading firms

can exploit their power

TCA:

Addressing the challenges of

integrating it into FX workflows

CASE STUDY:

Bringing a high level of automation

to a corporate treasury operation

BUILD OR BUY:

Key strategic, operational,

regulatory and technical

e-FX considerations

COVER INTERVIEW

JEFF WARD

CEO of FXSPOTSTREAM

LIQUIDITY • RISK MANAGEMENT • STP • E-COMMERCE


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Welcome to

e-FOREX

transforming global foreign exchange markets

May 2025

This month our Market Commentary feature is focused on ECNs

and is exploring the various reasons why they continue to attract

FX trading firms. ECNs are being increasingly recognised as

invaluable sources of data that can used to develop sophisticated

trading strategies, enhance risk management and inform market

microstructure research. Leading ECN providers are also looking

to enhance their value proposition by, for example, investing

in next generation technologies like AI and machine learning,

making themselves Global FX Code-compliant, handling credit

and expanding their product mix beyond FX. As the FX market

increasingly embraces automation and algorithmic trading, ECNs

look poised to grow in popularity due to their critical role in

supporting these advanced trading paradigms.

Susan Rennie

Susan.rennie@sjbmedia.net

Managing Editor

Charles Jago

charles.jago@e-forex.net

Editor (FX & Derivatives)

Charles Harris

Charles.harris@sjbmedia.net

Advertising Manager

Ben Ezra

Ben.ezra@sjbmedia.net

Retail FX Consultant

Michael Best

Michael.best@sjbmedia.net

Subscriptions Manager

David Fielder

David.fielder@sjbmedia.net

Digital Events

Ingrid Weel

mail@ingridweel.com

Photography

Tim Hendy

tim@thstudio.co.uk

Web Manager

Our Special Report in this edition takes a close look at the evolution

of Order Management Systems and how OMS solutions can be

tailored and engineered to deal with the specific requirements of FX.

OMS platforms have become much more than just trade routers and

can now facilitate predictive analytics, intelligent automation, risk

control and seamless multi-asset trading. As professionals at buy-side

firms gravitate toward multi-asset class solutions, the management

of workflows is changing the look and feel of vendor OMS solutions

turning them into a “strategic weapon” which can eliminate human

error, maximise automation and transform how institutional investors

navigate and command fragmented markets like FX.

Transaction Cost Analysis has evolved from a simple, ‘check the box’

into a service that helps firms improve understanding of technical

and operational risk and evaluate their trading performance. So

this month we examine how to integrate and implement it into

FX trading workflows. The future of FX TCA points towards greater

integration with predictive analytics and AI with systems able to

dynamically adapt trading strategies mid-execution and provide

deeper analytical insights into liquidity provider behaviours and

algorithm performance. Real-time, machine-readable live TCA which

plugs directly into automated execution engines, enabling adaptive

behaviour on the fly appears to be where we are heading with this.

A final word about our Ask A Provider feature this month which

tackles some questions about the well known conundrum of

whether to build or buy the infrastructure and skillsets required

for increasingly complex e-FX and fintech requirements. The issues

are no longer just about cost or speed versus control because new

technologies and operating models have redefined what’s possible

and transforming how firms approach this key decision.

SJB Media International Ltd

Suite 153, 3 Edgar Buildings, George Street,

Bath, BA1 2FJ United Kingdom

Tel: +44 (0) 1736 74 01 30 (Switchboard)

Tel: +44 (0) 1736 74 11 44 (e-Forex editorial & sales)

Fax: +44 (0)1208 82 18 03

Design and Origination:

Matt Sanwell, DesignUNLTD

www.designunltd.co.uk

Printed by Headland Printers

e-Forex (ISSN 1472-3875) is published bi-monthly

www.e-forex.net

Membership enquiries

Access to the e-Forex website is free to all registered

members. More information about how to register

can be found at www.e-forex.net

To order hard copies of the publication

or for more information about membership

please call our subscription department.

Members hotline: +44 (0)1736 74 01 30

Although every effort has been made to ensure the accuracy of the information

contained in this publication the publishers can accept no liabilities for

inaccuracies that may appear. The views expressed in this publication are not

necessarily those of the publisher.

Please note, the publishers do not endorse or recommend any specific website

featured in this magazine. Readers are advised to check carefully that any

website offering a specific FX trading product and service complies with all

required regulatory conditions and obligations.

The entire contents of e-Forex are protected by copyright and all rights are

reserved.

As usual I hope you enjoy reading this edition of the magazine.

Charles Jago

Editor

MAY 2025 e-FOREX 3


CONTENTS

May 2025

CONTENTS

Nicholas Pratt

ECN platforms

Paul Golden

OMS Report

Olli Lämsä

Build or Buy?

Arijit Ganguly

Restricted markets

Jeff Ward

e-Forex Interview

Lissele Pratt

EMIs

MARKET

COMMENTARY

12. ECNs: providing a direct,

transparent, and cost-effective

alternative to traditional FX

liquidity sources.

Nicholas Pratt explores the various

ways that ECNs offer a more

flexible, transparent, and efficient

solution for buy-side clients looking

to optimise their FX execution.

PROVIDER

VIEWPOINT

22. Electronic FX in restricted

markets.

Arijit Ganguly tells us more about

restricted markets and the future

prospects for opening them.

SPECIAL REPORT

24. How FX trading firms can

exploit the power of next

generation order management

systems.

The evolution of order

management systems means it is

more important than ever for FX

trading firms to carefully assess the

available solutions and how they

interact with other infrastructure as

Paul Golden discovers.

E-FOREX

INTERVIEW

32. FXSpotStream: still hungry to

succeed.

After joining the company as CEO

in January 2024, Jeff Ward and

FXSpotStream embarked on a

record setting year. Now, in Q2 of

year two, we caught up with him

again to see if he felt the growth

was sustainable, or a benchmark

on which to build.

TRADING OPERATIONS

40. Integrating Transaction Cost

Analysis into FX trading workflows.

Paul Golden outlines why market

participants need to consider various

factors specific to FX if they are to

maximise the benefits of TCA while

addressing the operational and

strategic challenges of integrating it

into their trading activities.

CASE STUDY

48. How LSEG helped a

multinational corporation

automate its treasury workflows to

optimise risk management and FX

trading.

By collaborating with LSEG FX,

Mondelez International has been able

to simplify workflows, access more FX

liquidity and improve the efficiency of

its treasury function

ASK A PROVIDER

52. Build versus Buy: Key

considerations for financial

institutions looking to capture the

benefits of further e-FX and digital

transformation

Olli Lämsä discusses some of the

operational, strategic, regulatory

and technical issues that banks and

financial institutions should consider

before deciding whether to build

or outsource their e-FX and fintech

requirements.

FINTECH

54. How Electronic Money Institutions

are promoting financial inclusion.

Lissele Pratt tells us more about

how Electronic Money Institutions

work and some of the ways they are

helping people to take their first real

steps into the financial system.

COMPANIES IN THIS ISSUE

B

BestX

p42

C

Capitalixe

p54

Centroid Solutions

p57

Citi

IFC

Crisil Coalition Greenwich p24

D

26 Degrees Global Markets p11

Deutsche Bank

p22

E

Euronext

p15

24 Exchange p10

F

FalconX

Finalto

FlexTrade

FXSpotStream

I

Ideal Prediction

ION

IPC

p8

p51

p10

p32

p42

p27

OBC

L

LCH

LSEG

M

MetaComp

Mondelez

N

New Change FX

O

oneZero

P

PLUGIT

p6

p21

p10

p48

p45

p42

p9

Q

Quod Financial

S

Saxo

SGX FX

smartTrade Technologies

Standard Chartered

Sterling Trading Technology

StoneX

Swissquote Bank

T

360T

Trading Technologies Int

TreasurUP

p26

p5

p19

p17

p8

p25

p29

p7

p14

p6

p52

4 MAY 2025 e-FOREX


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Contact: solutions-uk@saxomarkets.com

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This material is produced for marketing purposes only. Trading in financial instruments carries

some degree of risk, always ensure you fully understand all the risks before trading.

Read Saxo’s full disclaimer at www.home.saxo/legal/disclaimer/saxo-disclaimer.

MAY 2025 e-FOREX 5


360T launches its Digital Exchange 3DX

360T has launched its Digital

Exchange 3DX as a Crypto Spot

trading service, complementing

the platform’s current Crypto NDF

offering. 3DX is an institutionalonly,

MiCAR (Markets in Crypto

Assets Regulation) regulated trading

platform for crypto-assets, authorized

by BaFin and operating across the

EU. Formerly known as DBDX, an

initiative of Deutsche Börse Group’s

holistic Digital Strategy, 3DX has now

been successfully merged with the

Group’s FX entity to achieve synergies

on organizational, regulatory and goto-market

dimensions.

Carlo Kölzer

The digital business is led by Carlo

Kölzer, founder and CEO of 360T

and Head of FX and Digital Assets

of Deutsche Börse Group, who

commented, “Not only does the

launch of 3DX demonstrate Deutsche

Börse Group’s broader commitment

to be a leader in the digital assets

space, it represents a significant

milestone in 360T’s history as a global

marketplace that aims to grow as

a trusted partner in the evolving

crypto landscape and in line with the

increasing interests from our clients.”

TT FX connects with EBS and FX Spot+

NEWS

Trading Technologies International,

Inc. (TT), has announced that it has

integrated with the EBS Market

central limit order book (CLOB),

a regulated, anonymous all-to-all

matching platform. It also plans

to offer EBS Direct, a relationship

based disclosed platform, and CME

Group’s new FX Spot+ platform.

With this new connectivity, TT

is substantially expanding its FX

liquidity alongside its award-winning

futures and options offering. Tomo

Tokuyama, TT’s EVP & Managing

Director, FX, said: “This integration

is an important part of our TT FX

Tomo Tokuyama

build-out and gives our clients access

to another Tier 1 venue with the

ability to trade seamlessly across

asset classes. EBS Market has long

been the go-to venue for marketmaking

banks to hedge their FX

risk, and for other large FX market

participants to access firm liquidity in

an all-to-all CLOB. TT will give market

participants the ability to trade CME

Group FX futures and options, EBS

Market, EBS Direct, FX Link and the

recently launched FX Spot+, all side

by side in one EMS.”

LCH DigitalAssetClear now live

LSEG has announced that LCH SA has

launched its new LCH DigitalAssetClear

service. LCH DigitalAssetClear will

provide market participants with

access to the clearing of digital asset

derivatives traded on GFO-X. LCH

DigitalAssetClear has been developed

to ensure digital asset derivatives can

be cleared through a service that is

secure, segregated, highly regulated

and focused solely on digital asset

derivatives.

Marcus Robinson, Head of

DigitalAssetClear and CDSClear, LCH,

said: “We are delighted to launch this

Marcus Robinson

highly anticipated service from LCH SA.

The regulated clearing infrastructure

within LSEG’s post trade ecosystem

has allowed us to build something

meaningful for our participants and

address the availability of options

for a rapidly growing asset class. It is

essential that we find ways to offer

regulated, segregated and trusted

routes to provide customers with a

diverse breadth of services and we

are excited to continue working with

GFO-X to offer a regulated marketplace

for this asset class.”

6 MAY 2025 e-FOREX


LIQUIDITY

SOLUTIONS

THAT OPEN

NEW

HORIZONS

swissquote.com/institutional

MAY 2025 e-FOREX 7


LSEG’s SwapAgent completes first GBP/USD compression run

LSEG has announced that Post Trade

Solutions has successfully completed

its first GBP/USD multilateral

compression run at SwapAgent, the

service for the non-cleared derivatives

market. Post Trade Solutions brings

together Quantile, Acadia and

SwapAgent to minimise risk, reduce

cost, and improve capital efficiency.

This development enables participants

to target the majority of cross currency

swaps and directly responds to the

needs of market participants.

Andrew Williams, CEO of Post Trade

Solutions, LSEG, said: ‘At Post Trade

Solutions, we are continually looking

for ways to improve the post trade

landscape and enhance our services as

the market evolves. Adding multilateral

compression runs to currency pairs at

SwapAgent that are most demanded

by our network provides customers

with material gross notional reduction

while increasing efficiency. We have

already seen good adoption of

the service, and we look forward

to delivering more compression at

SwapAgent as the network grows.’’

Andrew Williams

FalconX and Standard Chartered announce strategic partnership

NEWS

FalconX has announced a strategic

partnership with Standard Chartered.

In the first phase of the partnership,

Standard Chartered will provide

a comprehensive suite of banking

services to FalconX globally, further

strengthening the platform’s

offerings for institutional clients. The

engagement will expand to include

a broader range of offerings and

mutual opportunities. Through this

collaboration, FalconX will initially

integrate Standard Chartered’s

banking infrastructure and access to

an extensive range of currency pairs,

enhancing the speed, scale, and

reliability of cross-border settlement

Matt Long

for its institutional client base. Matt

Long, General Manager, APAC &

Middle East at FalconX, commented:

“We are pleased to partner with

Standard Chartered, one of the most

forward-thinking global banks in

digital asset adoption. At FalconX,

we support trading and financing

for some of the world’s largest

institutions in digital asset markets,

and this relationship strengthens our

ability to deliver robust banking and

FX solutions to clients who rely on us

to operate in crypto markets.”

IPC Partners with Open Lake Technology

IPC has announced a strategic

partnership with Open Lake Technology

(OLT), a specialist technology provider

in compliance automation and

telephony performance management.

This collaboration addresses the

increasingly complex challenges

faced by financial organizations - and

other industry verticals - ensuring

regulatory compliance across complex

communications infrastructures.

The partnership integrates OLT’s

digital technologies for centralizing,

streamlining and automating

compliance processes within IPC’s Unigy

platform, accessible alongside - and

interoperable with - other IPC and

partner technology solutions.

“Financial institutions are under

immense pressure to meet regulatory

demands while optimizing operational

efficiency. This partnership exemplifies

the shared commitment of IPC and

OLT to support businesses in building

resilient, future-ready infrastructures

that integrate compliance with overall

performance management. Bringing

OLT’s state-of-the-art automation and

monitoring capabilities within our

global communications technology

environment enables our customers to

more easily streamline communications

compliance activities and meet

regulatory reporting obligations

with confidence,” said Colin Allison,

Compliance Product Manager at IPC.

Colin Allison

8 MAY 2025 e-FOREX


MAY 2025 e-FOREX 9


24 Exchange launches trading of FX NDS

24 Exchange has announced the launch

of FX Non-Deliverable Swaps (NDS)

trading, expanding the company’s range

of FX offerings on its robust global

platform. The new FX NDS product

mirrors the streaming functionality and

workflow that 24 Exchange currently

provides for FX Non-Deliverable

Forwards (NDFs) trading. NDS trading

features Standard Chartered Bank as

the single counterparty, and is accessible

via the 24 Exchange platform’s userfriendly

and efficient graphic user

interface (GUI). Importantly, the FX NDS

product is available over the same API

as other FX products ensuring efficient

and easy access. “We’re excited to

bring Non-Deliverable Swaps to our

platform, leveraging the strong demand

and engagement we’ve seen from our

institutional users in the NDF space,”

said 24 Exchange CEO and Founder

Dmitri Galinov. “This launch reflects our

continued focus on broadening access

to innovative FX products through costefficient,

technology-driven solutions

that enable users to efficiently maximize

liquidity.”

Dmitri Galinov

KCx integrates proprietary data into FlexTrade’s AI assistant

NEWS

FlexTrade Systems and Kepler

Cheuvreux, a leading independent

European financial services company

through its KCx execution services,

has announced the availability of

KCx’s sophisticated analytical suite

directly from FlexTrade’s AI assistant,

FlxAI, to deliver intelligent, highvalue

insights into client workflows.

Trading desks are increasingly

embracing conversational AI to

streamline decision-making and

extract actionable insights faster

than ever before. Andy Mahoney,

Managing Director, EMEA at

FlexTrade, stated: “Our existing

integration with KCx’s analytic suite

has proved popular with clients

Andy Mahoney

looking to source high-quality,

adaptive market intelligence.

Integrating the KCx data source

into FlxAI was a natural step to

extend the coverage to third-party

data, which is relevant, useful, and

timely to users. As the sell-side finds

new and unique ways to deliver

content to clients, we aim to provide

a seamless interface to access

all services available. With FlxAI,

connected to an abundance of data

sources and other AI agents, this

will ensure interaction is completely

natural.”

MetaComp launches StableX

MetaComp, a Major Payment Institution

licensed by the Monetary Authority

of Singapore (MAS) to provide Digital

Payment Token (DPT) services and

Cross-border Money Transfer services,

has announced the launch of StableX,

the next-generation infrastructure

platform purpose-built for cross-border

FX payments powered by stablecoins.

Developed for cross-border merchants,

institutions, payment service providers,

fintechs, and global businesses,

StableX enables always-on access

to foreign exchange with the speed,

cost-efficiency, and reliability required

in today’s digital-first economy. StableX

enables institutions to move money

across borders more efficiently through

stablecoin-powered FX rails that offer

real-time execution, reduced friction,

and continuous access to liquidity.

“Legacy infrastructure has carried the

industry far, but today’s businesses need

more agility”, says Mr Eddie Hui, Co-

President and Chief Operating Officer

of MetaComp. “StableX bridges that

gap by leveraging stablecoins to deliver

FX and settlement infrastructure that

works in harmony with existing systems,

enabling institutions and platforms to

scale global flows with confidence.”

Eddie Hui

10 MAY 2025 e-FOREX


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MAY 2025 e-FOREX 11


ECNs:

Providing a direct, transparent,

and cost-effective alternative to

traditional FX liquidity sources

Nicholas Pratt talks to leading ECN providers about the indispensable status

of the ECN and the factors driving traders’ demands

MARKET COMMENTARY

Image by Shutterstock

12 MAY 2025 e-FOREX


MARKET COMMENTARY

Nicholas Pratt

Electronic communication networks

(ECNs) have become a critical and

indispensable tool for FX traders. A

report written by WBR Research and

Euronext FX, published in late 2024,

underlined the indispensable role that

ECNs now have for FX traders. For the

majority of the survey respondents

(56%) access to data is the most

valuable benefit of an ECN, along

with diverse liquidity sources and

comprehensive trading platforms.

“Accessing the FX market often means

navigating a maze of fragmented

liquidity, limited transparency, and

restricted data availability,” states

Mercedes Ola, sales director for Euronext

FX. “But there’s a better way. ECNs

(electronic communication networks)

offer a more flexible, transparent, and

efficient solution for buy-side clients

looking to optimise their FX execution.

By connecting you with a pool of

liquidity providers optimised for your

needs, ECNs put the control back in your

hands and open up new opportunities

to maximise returns.”

LIQUIDITY INSIGHTS

As a consequence of the demands

of today’s FX traders, ECN providers

are looking to add advanced FX order

management to further enhance

execution efficiency, ensure better

pricing and reduce market impact.

“We offer insight on a number of

different levels,” says Simon Jones,

global head of product and liquidity,

FX at LSEG. “Central to our offering

is insight for Liquidity Providers (LPs)

into how they are engaging with their

clients, and the speed and depth of this

information continually evolves.”

“At the execution level there is now an

embedded process which gives clients

the ability to customise their panel

of banks according to the outcome

they want to achieve, or to source

recommendations on the right algo for

that pair and time of day,” says Jones.

“On a more custom level, we also have

execution specialists who focus on

how a clients’ actions impact their LPs,

helping bring greater understanding to

that relationship so that both parties

can engage more effectively.”

As the aforementioned survey shows,

ECNs are being increasingly recognised

as invaluable sources of data that can

used to develop sophisticated trading

strategies, enhance risk management

and inform market microstructure

research. “No individual client can

experience the range of conditions and

circumstances that the collective client

base of an ECN can,” says Jones.

“Harnessing that information and

turning it into actionable decision

points is where venues will differentiate

themselves. Aggregation of interest

is commoditised but designing

workflows to adapt to conditions, fed

by information about likely outcomes,

will give clients greater control over their

execution choices.”

Jones also believes that ECNs will

continue to grow in popularity with

many FX market participants as the

industry moves towards greater

automation and algorithmic trading.

“Through our platforms, our aim is to

scale back the need for the trader to

touch the commoditised trade,” says

Jones.

“The work can be done in advance with

the right automation tools – observe

the conditions, decide the terms upon

which you will trade, ensure you have

the correct level of liquidity that reflects

a best execution mandate, execute,

allocate, book – all no touch. What

is changing is the ability for those

decisions to adapt as information

changes, to date it has been too static.

The trader’s attention has to be on

where the greatest discretion is required

and automation tools free them up to

do that.”

FLEXIBLE TRADING

Another ECN provider aiming to

offer more flexibility to FX traders is

360T, the Deutsche Boerse-owned FX

trading platform that caters for both

buy and sell-side firms. According

to Vidura Seneviratne, head of spot

strategy at 360T, the platform offers

a “uniquely flexible and efficient”

trading environment by integrating

both disclosed and anonymous

liquidity into a unified environment.

“This setup provides buy-side clients

Simon Jones

“No individual client can experience the range of conditions and

circumstances that the collective client base of an ECN can.”

MAY 2025 e-FOREX 13


ECNs: providing a direct, transparent, and cost-effective alternative to traditional FX liquidity sources

MARKET COMMENTARY

“As the FX industry continues to evolve toward automation,

ECNs are ideally positioned to support both systematic and

hybrid trading models.”

Vidura Seneviratne

with broad access to liquidity while

reducing fragmentation and operational

complexity. With ultra-low latency,

deterministic infrastructure and real-time

data streaming, GTX ensures reliable

execution performance that supports a

range of trading strategies and enhances

transparency,” says Seneviratne.

“Moreover, clients already connected

to 360T through any other product can

easily access GTX using existing API or

GUI connectivity, eliminating the need

for extensive new technical builds. This

interoperability allows clients to scale their

operations rapidly and access liquidity

with minimal onboarding hurdles, while

benefiting from tools that support both

passive and immediate trading styles.”

ECN providers are also looking to put

more control back into their clients’

hands to open up new opportunities to

maximise returns by connecting them with

pools of liquidity providers that will cater

to their specific needs.

“360TGTX gives clients control over

how they access and manage liquidity

through features such as firm pricing,

last-looked liquidity, and access to dark

pools,” says Seneviratne. “This flexibility

empowers both makers and takers to

choose how they engage, based on

their execution goals and risk appetite.

Clients can also semi-automate their

decisions using logic built into the

platform, enabling them to dynamically

select the best way to interact with

different liquidity pools.”

“Custom liquidity pools can be

constructed and maintained by

segment, such as for systematic funds,

agency brokers, or regional banks and

credit-constrained clients can access

additional opportunities via Primeof-Prime

arrangements. All of this is

enhanced by 360TGTX’s ability to tap

into the firm’s broader network, offering

clients unmatched depth, diversity,

and control across counterparties,”

says Seneviratne. The direct interaction

between buy-side firms and multiple

liquidity providers in a single session that

is facilitated by ECNs brings multiple

benefits, according to Seneviratne.

“360TGTX enables clients to interact

directly with a diverse mix of bank, nonbank,

and systematic liquidity providers

in real time through a consolidated

trading interface. The ability to

simultaneously engage with disclosed,

anonymous, and semi-disclosed liquidity

within the same session significantly

enhances execution quality and

transparency,” says Seneviratne.

Semi-disclosed models, in particular,

provide a valuable balance between

access and efficiency by reducing the

need for extensive onboarding, credit

negotiation, and legal papering, says

Seneviratne. “This helps clients go

live faster without compromising on

control. With both GUI and API access

options, the platform caters to a broad

spectrum of users, from manual traders

at regional banks to high-frequency

strategies at hedge funds.”

Order management functionality is

also another area of development for

ECN providers. “GTX supports a suite

of advanced order management tools

including sweepable logic, pegged

orders, mid-point matching, and

full amount trading. All of these are

designed to provide traders with the

ability to control market impact, timing,

and visibility. These features can be

accessed via GUI or API, ensuring broad

usability,” said Seneviratne.

“Additionally, by integrating with 360T’s

broader execution infrastructure, such

as the execution management system

(360T EMS), and Deutsche Borse Group’s

wider network of companies, like the

independent algo-provider Quantitative

Brokers, GTX enables clients to build

multi-layered execution workflows,”

says Seneviratne. “This allows clients

not only to use existing tools but also to

experiment with new execution strategies

and structures in a flexible, modular

environment tailored to their needs.”

As previously stated, ECNs increasingly

recognised as invaluable sources of

data, so what are ECN providers doing

to cater to this trend? “The data

generated by 360TGTX’s deterministic

and low-latency environment is not just

rich but actionable,” says Seneviratne.

“When properly organised, this data

becomes a powerful foundation for

experimentation, allowing the platform

and its clients to provide intelligent

suggestions and guidance with

meaningful explainability. The richness of

GTX data—paired with the breadth of

our client base—enables learning loops

that support both alpha generation

and risk control. We are exploring

how to embed AI directly into liquidity

workflows, transforming this data into

real-time, decision-enhancing insights.”

“Since 360TGTX spans a broad and

diverse client base, it supports the

learning and optimisation of trading

models across multiple user types and

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ECNs: providing a direct, transparent, and cost-effective alternative to traditional FX liquidity sources

MARKET COMMENTARY

market conditions,” says Seneviratne.

“Disclosed and undisclosed trading

activity can either be analysed separately

or, in some use cases, combined to

answer broader execution or liquidity

questions, providing a more holistic view

of market behaviour.”

Some ECNs are also looking to enhance

their value proposition by, for example,

investing in next generation technologies

like AI and machine learning, making

themselves Global FX Code-compliant,

handling credit and expanding their

product mix beyond FX.

“360TGTX is actively exploring nextgeneration

technologies, including

AI-driven liquidity management and

real-time low-latency infrastructure

enhancements to better support

systematic trading and adaptive execution

models. The platform is fully compliant

with the FX Global Code, reinforcing its

alignment with global best practices and

trust in execution,” says Seneviratne.

“360TGTX has also expanded its

offering into metals and NDFs, asset

classes that are fully integrated into the

same platform infrastructure, credit

processes, and GUI/API environments

used for spot FX,” says Seneviratne.

“This approach allows clients to scale

across products without duplicating

effort, achieving operational consistency

while diversifying liquidity access.”

Seneviratne also believes ECNs will

continue to grow in popularity with

many FX market participants as the

industry moves towards greater

automation and algorithmic trading.

“As the FX industry continues to evolve

toward automation, ECNs like 360TGTX

are ideally positioned to support both

systematic and hybrid trading models.

The platform offers deterministic latency

and real-time market data essential for

algo execution, while its GUI ensures

that even clients without in-house

technology can access institutionalgrade

liquidity.”

“360TGTX is part of a one-stop shop

within the 360T ecosystem, bridging

disclosed and anonymous flow while

offering smart credit facilitation and

advanced execution tools. Unlike many

ECNs focused on a single segment or

geography, GTX’s strategic edge lies in

its ability to connect institutional and

Source: Transforming the FX Trading Desk: Strategies for Market Resilience

WBR Research and Euronext FX Q3 of 2024.survey

regional flow, GUI and API users, and

systematic and discretionary models—all

within a unified, scalable framework.

This structure not only supports current

client needs but also ensures scalability

as their strategies and infrastructure

evolve,” says Seneviratne.

CUSTOMISED LIQUIDITY

One of the attractions of ECNs is the

ability to offer customisable access to

liquidity pools tailored to their specific

trading needs, thereby opening new

opportunities to maximise returns, says

Vinay Trivedi, CEO of Singapore’s SGX

CurrencyNode. “Our ECN connects buyside

clients directly with multiple liquidity

providers-including top-tier banks,

market makers, and alternative sourcesaggregating

deep pools of liquidity that

reduce price slippage and trading costs.”

“This connectivity allows clients to

choose the type of liquidity they want,

such as firm or last look pricing, hidden

orders to minimise signalling, and

selective counterparties, giving them

greater control over execution strategies.

Advanced analytics and liquidity

management tools help clients optimise

order placement and improve fill quality

by understanding market impact and

execution performance,” says Trivedi.

Additionally, ECNs facilitate efficient

credit frameworks that consolidate

credit lines, enabling seamless access

to a broad portfolio of liquidity without

fragmentation, which enhances risk

management and trading efficiency,

says Trivedi. “By blending disclosed,

undisclosed liquidity pools and buyside

order book (in the case of SGX

CurrencyNode coming from our

network of clients on BidFX and

Maxxtrader) with innovative matching

technologies across multiple data centres

as NY4, LD4, TY3 and SG1, ECNs further

enhance execution opportunities while

ensuring compliance with market

standards, fostering a transparent

and reliable trading environment.

This combination of technological

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ECNs: providing a direct, transparent, and cost-effective alternative to traditional FX liquidity sources

MARKET COMMENTARY

“Ultimately, the data ecosystem fostered by ECNs contributes

significantly to the development of more resilient, transparent,

and efficient financial markets.”

Vinay Trivedi

innovation, customisable liquidity, and

enhanced transparency puts more

control in clients’ hands, enabling them

to tailor their FX execution to their

unique objectives and thus maximise

potential returns.”

The direct interaction between buy-side

firms and multiple liquidity providers

facilitated by ECNs provides multiple

benefits to market participants, says

Trivedi. “One of the foremost advantages

is access to deep, aggregated liquidity

pools sourced from a diverse array

of participants-including top-tier

banks, market makers, and alternative

liquidity providers. This aggregation

results in tighter bid-ask spreads,

reduced slippage, and improved pricing

opportunities, enabling buy-side traders

to execute large orders with minimal

market impact.”

In addition to liquidity depth, ECNs

provide unparalleled real-time

transparency by displaying live

order books and detailed market

depth information, says Trivedi. “This

visibility empowers traders to make

well-informed decisions based on

current supply and demand dynamics,

enhancing their ability to optimise

execution strategies. By eliminating

intermediaries and facilitating direct

order matching, ECNs also deliver faster,

more efficient trade execution with

significantly lower transaction costs.”

“Furthermore, this direct connectivity

supports the deployment of advanced

trading strategies through sophisticated

order types and automated execution

capabilities, offering traders greater

flexibility and control over their

outcomes. Collectively, these features

not only improve execution quality

and reduce costs but also unlock new

opportunities for buy-side firms to

maximise returns within a single trading

session, reinforcing the critical role of

ECNs in today’s evolving FX landscape,”

says Trivedi.

Leading ECNs are also addressing FX

execution by offering sophisticated order

management functionalities designed

to enhance efficiency, improve pricing

and minimised market impact, says

Trivedi. “For instance, platforms like SGX

CurrencyNode provide a comprehensive

suite of advanced order types-including

stop losses, trailing stops, iceberg orders,

TWAPs and basket algorithms that

empower traders with greater control

over their transactions, enabling them to

tailor execution strategies to specific risk

management and trading objectives.”

“Beyond order types, ECNs offer highly

customisable liquidity options, allowing

participants to select execution modes

such as firm or last look liquidity. Traders

can also leverage hidden order types

to reduce signalling risk and selectively

choose counterparties, further

optimising execution outcomes,” says

Trivedi.

SGX CurrencyNode has introduced

innovations like enhanced skew

protection, which minimises information

leakage on quotes and orders, alongside

a variety of order management

mechanisms such as full amount, skew

safe, collapse to mid, pegs, and dark

orders, says Trivedi. “These tools can be

combined flexibly, enabling clients to

design bespoke execution setups that

precisely align with their trading flows.”

“Moreover, we collaborate closely

with FX market participants to build,

optimise, and maintain bespoke liquidity

pools tailored to individual needs. By

integrating these customised pools with

cutting-edge matching technology, we

significantly improve order fulfilment

rates and execution quality. This holistic

approach not only enhances service

quality but also positions us as essential

partners for buy-side firms seeking to

maximise returns through smarter, more

efficient FX trading,” says Trivedi.

ECNs have become indispensable

sources of granular market data,

providing deep insights into order

flow, trade executions, and limit

order dynamics-key elements for

understanding price formation and

overall market behaviour, says Trivedi.

“This rich dataset empowers traders

to craft sophisticated strategies by

revealing how individual trades and

order placements influence price

discovery and market volatility. With such

detailed information at their disposal,

market participants can more accurately

time their entries and exits, gaining a

crucial competitive advantage through

enhanced informational awareness.

SGX CurrencyNode offers a rich data

set and analytics covering spread

report, fill ratio, mark-outs etc coupled

by AI backed actionable insights via

in-house developed tool MaxxAI, which

helps both market makers and taking

participants to optimise their execution.’’

Beyond the development of trading

strategies, the comprehensive data

supplied by ECNs plays a pivotal

role in advancing risk management

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ECNs: providing a direct, transparent, and cost-effective alternative to traditional FX liquidity sources

MARKET COMMENTARY

Source: Transforming the FX Trading Desk: Strategies for

Market Resilience WBR Research and Euronext FX Q3 of

2024.survey

frameworks, says Trivedi. “Real-time

transparency into liquidity conditions,

bid-ask spreads, and order book depth

allows firms to anticipate potential

market impact and adjust their trading

tactics dynamically to mitigate risk.

“Furthermore, ECN data has become

foundational for both academic

and industry research into market

microstructure, enabling rigorous

analysis of how trading protocols,

transparency, and information

asymmetries affect market quality

and efficiency. By leveraging this data,

researchers and practitioners alike can

refine algorithmic trading models,

optimise execution strategies, and

deepen their understanding of how

public announcements and private

information drive price dynamics.

Ultimately, the data ecosystem fostered

by ECNs contributes significantly to

the development of more resilient,

transparent, and efficient financial

markets,” says Trivedi.

As already mentioned, leading ECNs

are significantly enhancing their value

proposition by integrating nextgeneration

technologies such as AI and

ML to optimise trade execution, liquidity

management, and risk assessment.

These innovations enable faster, more

accurate, and cost-efficient FX trading

solutions that meet the evolving

demands of market participants. At the

same time, ECNs are committing to full

compliance with the FX Global Code-a

global framework that promotes ethical

conduct, robust governance, transparent

execution, effective risk management,

and efficient post-trade processesthereby

strengthening market integrity

and fostering client trust. For example,

SGX CurrencyNode enforces rigorous

KYC/AML procedures and requires all

participants to adhere to the Global FX

Code, ensuring best practices across its

platform.

Beyond spot FX, ECNs are broadening

their product offerings to include nondeliverable

forwards (NDFs), FX swaps,

and multi-asset strategies, supported

by advanced algorithmic trading and

automated matching technologies that

enhance price discovery and execution

quality, says Trivedi. Credit management

is also evolving, with ECNs integrating

sophisticated credit risk tools and

consolidating credit lines to provide

seamless access to diverse liquidity pools

while minimising counterparty risk.

“SGX CurrencyNode, for instance,

employs dynamic credit checks across

entities and data centers to optimise

credit utilisation. Furthermore, we tailor

solutions for algorithmic traders by

offering curated liquidity pools, lowlatency

API connectivity, and flexible

order types aligned with various trading

strategies, empowering clients to

achieve superior execution outcomes,”

says Trivedi.

“By prioritising regulatory compliance,

investing in cutting-edge technology,

expanding product diversity, and

enhancing credit facilities through CCP,

PFI, and Prime of Prime routes, (for

example SGX CurrencyNode offers

credit intermediation via 10 clearing

banks), ECNs are positioning themselves

as comprehensive FX trading hubs.

This holistic approach not only meets

the complex needs of today’s market

participants but also opens new avenues

for maximising returns and sustaining

long-term growth in a competitive FX

landscape.”

As the FX market increasingly embraces

automation and algorithmic trading,

ECNs are poised to grow in popularity

due to their critical role in supporting

these advanced trading paradigms,

says Trivedi. “ECNs provide direct

market access to a broad spectrum of

liquidity providers via a single electronic

platform, enabling instantaneous trade

execution with minimal latency-an

essential feature for high-frequency

and algorithmic strategies that demand

speed and precision.”

“Their transparent pricing and real-time

order book data empower algorithms

to optimise execution by securing the

best available prices while minimising

market impact. Additionally, ECNs offer

advanced order types and customisable

liquidity options tailored to sophisticated

algorithmic needs, enhancing risk

management and improving fill quality.

The removal of dealing desk intervention

and the provision for anonymous trading

further promote fairness and reduce

information leakage, which is crucial

for algorithms seeking to minimise

signalling risk,” says Trivedi.

“Complementing these capabilities,

the proliferation of high-quality

analytics tools has become instrumental

in refining trading strategies. This

integration of cutting-edge analytics

with ECN infrastructure empowers both

institutional and retail participants to

harness technology effectively, achieving

superior execution quality and enhanced

cost efficiency in today’s fast-evolving FX

landscape,” he concludes.

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Electronic FX in

restricted markets

By Arijit Ganguly, Head of Asia EM FX eTrading & NDF Asia at Deutsche Bank

PROVIDER VIEWPOINT

Arijit Ganguly

The electronification of FX,

particularly spot, has been extensively

documented, making it amongst

the most liquid financial markets.

However, certain segments of this,

within emerging markets, remain

fragmented and offer limited access

due to restrictions on capital or

current accounts, or both. These

restrictions, often introduced

during periods of financial stress

to prevent capital outflows and

speculative activities, have not

always been reversed, leading to the

term ‘restricted’ markets. In such

scenarios, parallel offshore markets

often emerge, allowing for hedging

exposure when access to deliverable

spot or forward markets is restricted.

Each restricted market has its own

nuances and regulations, and

Deutsche Bank’s extensive onshore

presence means this is a real area of

strength for us and consequently for

our clients.

MANUAL VS. ELECTRONIFIED

MARKETS

Restrictions do not necessarily mean

that these markets have bypassed

electronification. Depending on the

size of the economy, countries like

India and South Korea have developed

local electronic trading platforms for

interbank FX trading. While these

platforms remain closed to foreign

participants, they often have substantial

trading volumes with liquidity

comparable to more open markets.

Domestic market data and API-based

hedging, where available, enable

electronic pricing. However, foreign

access typically involves additional

prerequisites such as document checks

and transaction reporting to meet

regulatory requirements, making them

harder to access. Most of these markets

also operate within fixed trading hours,

preventing round-the-clock availability.

Therefore, while these markets may be

electronified, restricted access often

requires manual intervention in parts of

the FX workflow.

SHIFTS IN MARKET DYNAMICS

Several changes are underway in

restricted markets. Firstly, there is a

growing demand for faster and more

transparent execution. Asset managers

increasingly expect the same level of

access to these markets as they have

with more developed spot markets.

Technology solutions like Deutsche

Bank’s HausFX are designed to

automate these workflows, allowing

clients to access the markets and

meet regulatory obligations without

increasing manual work or operational

risk. Secondly, restrictions on accessing

onshore markets can stifle capital flows

and, in some cases, prevent market

inclusion in major indices. Many local

authorities are now keen to deepen

Most restricted markets operate within fixed trading hours, preventing round-the-clock availability

22 MAY 2025 e-FOREX


PROVIDER VIEWPOINT

The government of South Korea has eased regulations to enhance access to its FX and bond markets

their financial markets and attract

foreign investment, prompting moves

to liberalize FX regulations.

CASE STUDY: SOUTH KOREA

South Korea recently undertook a

major shift after decades of tight

controls. The government eased FX

regulations to enhance access to

its FX and bond markets. Foreign

investors with an Investment Exclusive

Account (IEA) were granted access

to the onshore FX market under the

Registered Financial Institution (RFI)

scheme. Documentation checks before

every transaction were eliminated, and

reporting requirements were lightened.

Trading hours were extended to 2:00

a.m. local time to accommodate global

participants. This initiative was well

received, allowing foreign participants

who had relied on the offshore NDF

market to access the onshore market

easily via RFIs. Interbank liquidity

increased, and extended trading

hours enabled hedging flows through

the London close. These regulatory

reforms may have been instrumental

in South Korea’s inclusion in the World

Government Bond Index (WGBI),

setting a precedent for the benefits of

easing restrictions.

FUTURE PROSPECTS FOR

OPENING MARKETS

At Deutsche Bank, we have been a

key partner to both clients and local

authorities in the journey of easing

market access. Extended trading

hours allow clients to operate in their

Asset managers increasingly expect the same level of access to restricted markets as they have with more developed

spot markets

preferred time zones, and there is

growing demand for end-of-day fixing

services that align with broader FX

rebalancing flows. Clients no longer

have to wait for the local market to

open—they can hedge exposures as

soon as needed, whether for equities,

bonds, or portfolio rebalancing. This

unlocks opportunities for automated

workflow solutions within HausFX,

tailored to the timing and nature of

capital flows. Licensing will remain a

factor for operating in onshore markets,

and how this evolves will be worth

watching. As these markets mature,

we see significant demand from clients

for a broader suite of execution tools,

similar to those they are familiar with

from G10 markets, such as algorithmic

execution and electronic order

capabilities.

IMPACT ON DOMESTIC PLAYERS

The opening of restricted markets

does affect domestic players, though

not necessarily negatively. Domestic

banks often focus on local clients, while

foreign investors typically access the

market via global banks, which may

partner with local institutions or use

their own branches. This partnership

could see increased demand from

global banks for services such as

reporting and settlement looking to

avoid operational risks and instead

focus on client execution. Local

markets also deepen through foreign

participation. For example, Korean

banks now have new counterparties

to hedge risk, reducing transaction

costs for clients. Given that local

markets have historically been traded

on voice, especially on the client side,

electronification typically increases

both competition and market data

availability, consequently improving

transparency and lowering execution

costs, including hedging costs for

local players. On balance, it’s a natural

progression that benefits the majority

of market participants.

MAY 2025 e-FOREX 23


SPECIAL REPORT

OMS

Image by Shutterstock

24 MAY 2025 e-FOREX


SPECIAL REPORT

How FX trading firms

can exploit the power of

next generation order

management systems

Paul Golden

A new report from Crisil Coalition

Greenwich (OMS benchmarking:

providers, market sizing and what’s

next) highlight the challenge

of keeping up with the rapid

transformation of front-office trading

technology systems.

OMS providers are adding

capabilities like portfolio modelling

tools, compliance and third party

connections. They are also enhancing

workflow capabilities such as realtime

compliance checks and other

supportive capabilities, as well as

product or function-specific features

like hedging, trading tools and

portfolio management functionality.

The pace of change is unlikely to

slow with systems vendors investing

20% or more of product revenue in

R&D associated with their platforms.

Vendors are working to add open

APIs, automation and cloud-native

offerings to enable version-less

updates and faster data crunching

and output. Mobile capabilities

and web-based apps are also on

the horizon, while some vendors

are adding data management

capabilities and new analytics like

pre-trade TCA and liquidity tools.

An order management system

will streamline the entire

order and trade life cycle for

an investment firm or brokerdealer,

making it faster, more

accurate and more controlled.

This obviously strengthens the

compliance and auditing required

in regulated markets and while FX

is an unregulated market, market

participants are regulated and are

subject to compliance requirements.

FUNCTIONALITY ACROSS ASSET

CLASSES

There are some common features

or requirements of an order

management system across any asset

class explains Mike Baradas, OMS

product manager at Sterling Trading

Tech. “In terms of technology, the FIX

messaging system is standard across

most asset classes, including FX,”

he says. “But FIX only covers order

routing and order execution reports.

An OMS that has full API architecture

can integrate with the different

systems that could be involved in the

investment or trading lifecycle of a

particular firm.”

OMS has evolved from a functional

necessity to a strategic weapon -

eliminating human error, maximising

automation and transforming how

institutional investors command

fragmented markets.

That is the view of Medan Gabbay,

chief executive officer at Quod

Financial, who goes on to outline

some of the key features and

functionality.

MAY 2025 e-FOREX 25


How FX trading firms can exploit the power of next generation order management systems

SPECIAL REPORT

“Most OMS platforms fundamentally lack the functionality

required to thrive in a world driven by data intelligence, which

is why many larger firms choose to build their own systems.”

Medan Gabbay

“Today’s best OMS platforms are not

just trade routers,” he says. “They are

AI-fuelled, low latency ecosystems

enabling predictive analytics,

intelligent automation, risk control

and seamless multi-asset trading out

of the box.”

Gabbay observes that an FX-ready

OMS must do more than handle

tickets. It needs to understand

fragmented liquidity, handle multilisted

instruments and dynamically

route orders with algorithmic

intelligence across opaque venues.

He warns that many systems have

shortcomings that have persuaded

firms to develop their own solutions.

“Most OMS platforms don’t just need

additional modules to support the

needs of market participants,” says

Gabbay. “They fundamentally lack

the functionality required to thrive in

a world driven by data intelligence,

which is why many larger firms

choose to build their own systems.”

“Vendor products often fail to

address the complexities of managing

multi-asset strategies and data-driven

decision making,” he continues.

“Attempting to retrofit such

capabilities into existing products is

either prohibitively expensive or so

misaligned with the core design that

it is nearly impossible to achieve.”

From a bank perspective, some of the

main drivers around needing an OMS

relate to an obligation to enforce

need-to-know policies. The order

book exposes a lot of information

to trading desks and sales desks as

to potential price action at various

different price levels and banks need

to ensure that only the people who

should see an order can see it to

ensure information is not leaked

into the market as to where there’s

interest.

ELECTRONIFICATION IS

DRIVING DEMAND

There is also increased desire to

electronify workflows explains

Cormac Walsh, head of FX trading

products at ION Markets.

“Banks want to capture orders

electronically, so we are highly

integrated with their digital strategy

to capture orders from single dealer

platforms, sales platforms, multidealer

platforms, APIs and all sorts

of internal divisions within the

bank and to route those orders

to the appropriate algorithms to

OMS vendors are working to add open APIs, automation and cloud-native offerings to enable version-less updates and faster data crunching and output

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MAY 2025 e-FOREX 27


How FX trading firms can exploit the power of next generation order management systems

SPECIAL REPORT

“An OMS that has full API architecture can integrate with the

different systems that could be involved in the investment or

trading lifecycle of a particular firm.”

Mike Baradas

automatically execute - and only on

an exceptional basis to post them for

a trader to manage,” he says.

On the question of how OMS

solutions are tailored and engineered

to deal with the specific requirements

of FX, Walsh says that although order

management systems traditionally

focused on automated management

resting, fixing and algorithmic

orders for FX cash, modern systems

also extend into cross-asset FICC

workflows – handing orders on vol,

fixed income and commodities.

The relationship between OMS,

PMS and EMS front office solutions

has evolved according to Audrey

Costabile, senior analyst for Coalition

Greenwich market structure &

technology.

“As technology and data become

more integrated, the lines between

PMS, OMS and EMS solutions

have blurred,” she says. “Although

optimisers are offered a la carte

by some vendors, OMS solutions

providers are including them in their

offerings. Most equity traders prefer

a standalone EMS but this is also

changing due to the desire for a

multi-asset class EMS, more trader/

portfolio manager overlap and firm

size - smaller firms may prefer more

front-to-back boxes.”

ION Markets FX does a lot of

work automatically capturing flow

generated from PMS systems but

also from other not-so-obvious

divisions of a bank such as custody,

transaction banking or portfolio

hedging.

“All these activities generate orders

and there is a lot of focus on being

able to automatically capture those

orders so that if a client is doing, for

example, a portfolio rebalancing on

their equities portfolio at the end of

the month and there is FX exposure

generated on that, they are able to

automatically post that FX exposure

as orders into the OMS,” says Walsh.

OMS STRADDLES MULTIPLE

SYSTEMS

According to Baradas, the OMS can

be seen as an umbrella platform that

bridges the PMS and EMS, whether

it is controlling routing of orders to

different exchange venues/liquidity

destinations or handling the risk

controls to make sure orders are not

oversized or routed to the wrong

venues.

OMS HAS EVOLVED FROM

A FUNCTIONAL NECESSITY

TO A STRATEGIC WEAPON -

ELIMINATING HUMAN ERROR,

MAXIMISING AUTOMATION

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MAY 2025 e-FOREX 29


How FX trading firms can exploit the power of next generation order management systems

SPECIAL REPORT

“As technology and data become more integrated, the lines

between PMS, OMS and EMS solutions have blurred.”

Audrey Costabile

“This includes margin calculations,”

he says. “When you get into

derivatives trading there are very

specific regulatory or clearing

requirements in terms of margin

calculations that the order

management system will handle.”

Gabbay believes the future belongs to

those providers who can consolidate

OMS, PMS and EMS into a single

adaptive fabric, breaking silos to

create real time intelligence from pretrade

to post-trade.

On the main challenges faced when

consolidating these systems, he

observes that OMS serves as the

central hub, balancing a wide array

of functions with often conflicting

demands. While PMS prioritises

workflows over performance, EMS

focuses on performance and data

intelligence. “Positioned between

the two, OMS frequently lacks the

technical and functional capabilities

necessary to effectively bridge these

processes,” says Gabbay. “The idea

of consolidating PMS, OMS and EMS

into a single solution feels unrealistic.

Instead, the most immediate benefits

will likely come from leveraging PMS

for core operations while adopting a

data-driven OMS/EMS for advanced

needs.”

Currently, the industry - across all

asset classes - is heavily focused on

cost-cutting, with an ongoing race

to reduce vendor spending. This

environment is pushing clients toward

all-in-one solutions largely out of

fatigue and a lack of willingness to

invest in alternatives.

“While some vendors offer more

modern solutions unburdened by

legacy systems, they remain rare,”

suggests Gabbay. “Significant

changes in industry mindset and

investment would be required for

such alternatives to gain widespread

adoption.”

As technology becomes an

increasingly critical differentiator,

funds are showing less interest in

investing in it, he adds.

“This trend will likely lead to further

consolidation as firms lacking the

necessary technical expertise find

themselves unable to compete. The

buy-side is, in effect, setting itself

up for failure in the medium term.

Sticking to outdated thinking in an

era that demands innovation will

inevitably drive systemic change.”

CLOUD OFFERS UNIVERSAL

OPTION

Gabbay’s response to the question

of what deployment choices are

available for firms of different sizes

who are looking for OMS to automate

their order flows from low-touch to

no-touch is that whether the client

is a boutique desk or a global titan,

cloud native microservices allow lowtouch

to no-touch trading without

being shackled to legacy anchors.

When asked about the deployment

choices available, Baradas observes

that the traditional software solution

for an order management system for

a larger firm is typically an on-premise

solution.

Currently, the industry - across all asset classes - is heavily focused on cost-cutting pushing clients toward all-inone

solutions

Then there is the cloud option, which

is typically more scalable and faster in

terms of innovating and developing

the system.

30 MAY 2025 e-FOREX


SPECIAL REPORT

“In between you have a solution

where the database remains in your

own data centre but you want the

user interface available on the web or

on a mobile platform,” says Baradas.

“This is what you would call a hybrid

solution between on-premise and

cloud. Typically it is an API architecture

that makes that happen, connecting

with the best-in-class solution you are

looking to provide to your customer.”

“The OMS must scale to support the most volatile market

conditions and provide enterprise-grade resilience with

instantaneous failover across all tiers.”

longer a privilege of the giants, says

Gabbay. “AI-driven OMS platforms

now weaponise smaller players

with execution precision, predictive

analytics and scalable automation,”

he adds.

The Crisil Coalition Greenwich report

notes that as professionals at buy-side

firms gravitate toward multi-asset

class solutions, the management of

workflows - including books of record,

compliance checks, audit trails and

other downstream capabilities - is

changing the look and feel of vendor

OMS solutions.

Market participants are obviously

interested in how the ongoing

development of OMS is driving

innovation and efficiency in multi-asset

sell-side trading. Baradas refers to this

as a technology issue in terms of being

able to handle high messaging rates.

“There is not a huge difference

between what you would call an

institutional firm (where they may

only have large customers with 500

or 1,000 accounts but are actively

trading or have active transactions that

run into the hundreds, thousands,

or millions of transactions per day)

and a retail broker where you can

have smaller account sizes but they

are going to have thousands, tens

of thousands or even hundreds of

thousands of accounts,” he says.

From a technical perspective, the

messaging requirement is the same so

the need is for a technical architecture

that is high throughput and low

latency.

AI BOOSTING SYSTEM

SOPHISTICATION

Multi-asset sell-side trading is no

Gabbay recommends FX market

participants choose an OMS partner

rather than just a vendor - one

that brings native FX knowledge,

AI-powered decision support,

cross-venue routing agility and a

roadmap beyond today’s liquidity

fragmentation.

When it comes to implementation,

Baradas says the sell-side has a

decision to make on buy versus build.

“Typically, what we see smarter

firms do is buy solutions that handle

functions that are standard across

every asset class such as regulatory

requirements, risk controls or margin

calculations,” he says. “They are then

spending their investment dollars

on building a unique customer

experience.”

Costabile recommends working

with a vendor that covers a range of

products.

“For instance, can all FX and

derivatives be analysed using

one vendor?” she says. “Can FX

hedges be automatically generated

for equities trading? If an OEMS

is desired, how does execution

work? Is there interoperability with

different venues? Are the tools

for best execution and protocols/

algos coming from the venue or

the OEMS? Is the solution open

and modular, allowing for tweaks

necessary for a particular strategy?

Finally, how is support assigned and

Cormac Walsh

is it available at all times?”

Operational stability is one of

the first things to consider when

looking for a potential OMS provider

suggests Walsh.

“An OMS outage isn’t simply system

downtime – it is equivalent to

flying blind with live risk,” he says.

“This creates significant market,

operational and reputational risk.

The OMS must scale to support the

most volatile market conditions and

provide enterprise-grade resilience

with instantaneous failover across all

tiers.”

Another consideration is

performance at the tail end of the

performance curve. In the most

volatile conditions, can the OMS

keep up with the market if prices are

moving 20-50 times a second across

thousands of orders in hundreds

of pairs where each rate update is

potentially creating an order trigger

event?

“The OMS needs to be designed to

be very operationally stable but also

capable of performing in the most

extreme conditions,” adds Walsh.

MAY 2025 e-FOREX 31


THE E-FOREX INTERVIEW

Jeff Ward

32 MAY 2025 e-FOREX


THE e-FOREX INTERVIEW

FXSpotStream:

Still hungry to succeed and provide

the industry’s most cost effective

trading model for both the buyside

and sellside alike

After joining the company as CEO in January 2024, Jeff Ward and FXSpotStream embarked on

a record setting year. Now, in Q2 of year two, we caught up with him again to see if he felt the

growth was sustainable, or a benchmark on which to build.

Jeff, thank you for taking the

time to speak with us. 2024 was a

historic year for the company; could

you have asked for a better way to

start your new role?

I had said before the interview process

that it was the FSS role or nothing

for me. I had seen the company from

the outside and admired how they

did business and what they stood for.

Once I started in January, I quickly

realized that I had been right in my

assumptions. There was a very high

standard set for the workload, and

it was great to join a team that was

highly motivated to succeed.

I was very impressed with the level of

support offered to clients and LPs by

the FSS team. It was something I had

been aware of in the past, but across

the board, there is a level of proactivity

that is extremely reassuring for those

connected to FSS. We are always

looking to get ahead of a potential

issue and find answers as quickly as

possible. It’s a level of care that is often

lost as a company grows, but here,

there is a high level of pride taken by

everyone to ensure that the level of

service does not drop.

And how has 2025 started for

FXSpotStream?

From a volume perspective, 2025 has

started with a bang; February, March

and April providing consecutive record

months from an ADV standpoint. From

an overall standpoint, our ADV is up

38.97%, while our Spot ADV is up

39.66% YTD (January-April 2025 vs

2024).

While we have certainly enjoyed the

fast-paced start to the year, what

is most important to our clients

is that the service has operated

extremely well, especially in terms of

performance during periods of high

volatility. Our reject rate has remained

consistently low, which I would put

In January we set a new overall ADV

record, and things did not slow down

after that – we went on to set six new

overall ADV records in 2024. What

was more impressive though was how

these records were being set. While

Spot has always been the strength of

the Service, we were taking significant

steps in all products, most notably in

FX Swaps and NDFs.

Were there any surprises when you

came into the role?

I don’t know if I’d call it a surprise, but

MAY 2025 e-FOREX 33


FXSpotStream: Still hungry to succeed and deliver the highest level of service

THE E-FOREX INTERVIEW

While we have certainly enjoyed the fast-paced start to the year, what is most important to our clients is that the service has operated extremely well, especially in

terms of performance during periods of high volatility

down to our fully upgraded network

and trading infrastructure, but also the

work done by our Support Team to be

proactive and get ahead of potential

issues.

With such a strong start to your

tenure, where do you go from here?

While it has been a tremendous start

to the year for the Service, it would

not have been possible without the

work that our CTO, Tom San Pietro and

his team put in migrating the entire

Service to a new Ultra Low Latency

Network (ULL).

Our CTO Tom San Pietro and his team have put in a great deal of work migrating the entire Service to a new

Ultra Low Latency Network (ULL)

Volumes have continued to grow

rapidly over the Service and our

job is to ensure that our clients can

always access the market confidently,

especially when there are large global

events that are driving market activity.

As with any technology, over time it

can become outdated. Two years ago,

we began the huge task of migrating

all clients and LPs to a new network

that aimed to deliver market data with

a maximum latency time of no more

than 250 microseconds. While many

will reference average latency times,

and we agree there is value in doing

so, our goal was to ensure that at

maximum volatility, the market could

34 MAY 2025 e-FOREX


THE e-FOREX INTERVIEW

What clients now connecting to FSS can expect is a network built for high volumes, with extremely low latency that is highly competitive from a performance standpoint.

rely on the Service to perform at a

high level, regardless.

What clients now connecting to FSS

can expect is a network built for high

volumes, with extremely low latency

that is highly competitive from a

performance standpoint. Our volumes

and client base are a testament to

the level of satisfaction our end users

experience on the Service.

identify products and client segments

in which we felt we could grow,

and the additions from a product

standpoint that we would need to

make to increase our appeal to them.

Can you share your findings?

In terms of client types, the Systematic

Hedge Funds have really proven to

be a sweet spot for FSS in recent

I believe complacency is something

that has no place in the FX market.

While 2024 was extremely exciting

from a number’s perspective, we

realize that people are starting to take

note of FSS and we must continue to

do a great job every day.

We cannot afford to stand still and

admire our hard work, because

someone will overtake us. Towards

the end of 2024, we began work to

Our volumes and client base are a testament to the level of satisfaction our end users experience on

the Service

MAY 2025 e-FOREX 35


FXSpotStream: Still hungry to succeed and deliver the highest level of service

The new GUI will leverage many of the

recurring needs we heard expressed

by those members of the Macro HF

community with which we spoke,

with the unique scalability of the

FXSpotStream model. While we feel

there will be additions to be made

down the line, we are confident that

we are coming to market on day one

with an established and extremely

competitive product and a compelling

pitch.

For those not familiar, what is the

FXSpotStream model?

THE E-FOREX INTERVIEW

We have seen 4 new LPs go live and continue to have conversations with new ones

years. Our offering can be rolled Given our strong presence in the

out company wide, while individual Systematic Hedge Fund world, we

managers can customize their own have decided to work with our

liquidity pool with ease. New pods technology partner to provide a new

can go live with very little work to be GUI offering, available and tailored

done, and the testing process remains to Macro Hedge Funds trading

consistent.

needs.

FXSpotStream was originally founded

to alleviate growing costs associated

with the electronification of the FX

market. As a result, our model has

always aimed to be cost effective for

both the buyside and sell side alike.

For our Liquidity Providers, we offer

a flat fee model which means that

regardless of their monthly volumes,

they know the bottom line and in

effect, the more business they put

through FSS, the lower their effective

commission rate would be.

In 2023 we introduced a number

of new plans which were a mixture

of the subscription fee model and

a commission-based pricing model,

to allow for new LPs to join the

Service and increase their volumes

over time. Since implementing these,

we have seen 4 new LPs go live –

ANZ, Deutsche Bank, Natwest and

Wells Fargo – and continue to have

conversations with new LPs.

We feel that rate cards that suit our

LPs will ultimately be reflected in

better pricing for our clients as the LPs

will want to do that business over FSS

rather than a channel where they are

being charged a higher per million fee.

Our API offering allows clients to connect and receive pricing from multiple banks

From a client perspective, we have

normalized the offerings of all 18

of our liquidity providers and made

36 MAY 2025 e-FOREX


THE e-FOREX INTERVIEW

We feel that there is a growing opportunity for a alternative in FX Swaps and that our unique offering makes us a strong candidate to fill this need

OUR AI ENGINE

ENABLES A FULLY

CUSTOMISED

ONBOARDING

EXPERIENCE

Clients pay nothing to access pricing from as many of the LPs as they have a relationship with and FSS supports pricing in Spot, Swaps, Forwards, NDF, NDS and Precious Metals

MAY 2025 e-FOREX 37


FXSpotStream: Still hungry to succeed and deliver the highest level of service

THE E-FOREX INTERVIEW

them available via a single API or

GUI. Clients pay nothing to access

pricing from as many of the LPs as

they have a relationship with, and

FSS supports pricing in Spot, Swaps,

Forwards, NDF, NDS and Precious

Metals out of co-location sites in

New York, London and Tokyo.

In addition, we have undergone

the same process with the algos of

the participating liquidity providers

and clients can access these in the

same way, with no charge from

FXSpotStream.

Furthermore, FXSpotStream is

In terms of client types, the Systematic Hedge Funds have really proven to be a sweet spot for FSS in recent years.

Our offering can be rolled out company wide, while individual managers can customize their own liquidity pool with ease

vendor agnostic, meaning that if

you use a technology provider for

any of your connectivity, network

or trading needs, FSS can often do

the work to integrate with them,

minimizing the disruption to your

operations.

Are there any other advances in

the pipeline?

After recent announcements in the FX

industry, we feel that there is a growing

opportunity for a alternative in FX

Swaps and that our unique offering

makes us a strong candidate to fill this

need. As mentioned, we are looking

at Macro Hedge Funds to grow FX

Swaps activity on the service. Given

Hedge Funds large market interest and

sophisticated needs in the FX Swaps

market, we are also targeting the end

of Q2 as a go live date for supporting

Streaming FX Swaps.

This is an area that we have

paid close attention to and been

monitoring interest from the market

for a while now. Working closely with

early adopter LPs to introduce this to

our offering before opening this up

more broadly.

It certainly seems like there is a lot

more to come for FXSpotStream.

Absolutely. We are always looking for

ways to improve the Service, but what

has to remain consistent is the level of

pride and attention to detail that the

staff show daily.

At FXSpotStream we have a team that

are hungry to succeed and provide

the highest level of service possible. It

is about getting the most out of these

relationships for both our clients and

LPs and we are extremely motivated

to do just that.

38 MAY 2025 e-FOREX


THE e-FOREX INTERVIEW

AT FXSPOTSTREAM

WE HAVE A TEAM

THAT ARE HUNGRY

TO SUCCEED AND

PROVIDE THE

HIGHEST LEVEL OF

SERVICE POSSIBLE

MAY 2025 e-FOREX 39


Image by Shutterstock

TRADING OPERATIONS

Integrating

Transaction Cost

Analysis into FX

trading workflows

Paul Golden outlines why market participants need to consider various factors specific to FX if they

are to maximise the benefits of TCA while addressing the operational and strategic challenges of

integrating it into their trading activities.

40 MAY 2025 e-FOREX


TRADING OPERATIONS

TCA in FX requires highly granular,

high frequency data, including

tick-by-tick quotes and trades from

diverse liquidity sources such as

ECNs and bank/non-bank streams.

Platforms providing comprehensive,

microsecond-level timestamps are

essential to measure accurately against

dynamic benchmarks like risk transfer

price or arrival price.

The decentralised FX market

complicates benchmarking due to

fragmented liquidity and the absence

of a unified pricing reference.

Comprehensive data aggregation and

normalisation from multiple liquidity

sources are essential to create accurate

benchmarks reflective of true market

conditions.

“The ability to seamlessly integrate

proprietary logic via tools such as

AlgoBox further enhances the depth

and precision of analytics throughout

the trading lifecycle, from pre-trade

to post-trade, supporting ultra-low

latency execution,” observes John

Stead, director of sales enablement

and marketing at smartTrade

Technologies.

Sophisticated TCA frameworks rely on

high frequency, time-stamped data

that captures critical microstructural

details. But none of this matters

unless those metrics are benchmarked

against accurate data according to Paul

Lambert, CEO New Change FX.

“By aggregating price feeds from

across the FX ecosystem and

constructing a real-time mid-rate

derived from the best bid and offer

MAY 2025 e-FOREX 41


TRADING OPERATIONS

Integrating Transaction Cost Analysis into FX trading workflows

“If you are a high frequency trader, execution cost represents a

large chunk of your P&L so you have to be hyper-vigilant, whereas

a buy-side person doing one trade a day has different priorities.”

John Crouch

available, our data enables clients

to perform meaningful, apples-toapples

performance analysis,” he says.

“We have also developed granular,

independent forward and swap

benchmarks, which are dynamically

adjusted for basis shifts and interest

rate differentials.”

SERVICE HAS EVOLVED

SIGNIFICANTLY

Meanwhile John Crouch, CEO Ideal,

observes that TCA has evolved from

a simple, ‘check the box’ to a service

that improves understanding of

technical and operational risk.

“Market participants approach TCA

in a different way depending on

the extent to which execution costs

dominate their P&L,” he says. “If you

are a high frequency trader, execution

cost represents a large chunk of your

P&L so you have to be hyper vigilant,

whereas a buy-side person doing one

trade a day has different priorities.”

BestX cleans market data and then

adjusts it to the type of transaction. It

also has a proprietary expected cost

model that takes into account the size

of the transaction and the liquidity

and volatility at that point in time,

enabling clients to not only evaluate

their trade performance against

market data but also the expected

cost at the point of execution.

“Specific timestamps around when

the trade was sent to the trader, when

they began the order and when it

was completed give clients a better

understanding of their transaction

costs,” explains Yusuf Nurbhai, head

of BestX.

He observes that there isn’t a

single benchmark to evaluate their

transaction costs against, which is

where technology has evolved to allow

clients to define the asset class-specific

benchmarks that are most relevant.

“They can achieve a standardised

view around execution quality from

a cost perspective, but they will have

different ways of evaluating trading

costs,” adds Nurbhai. “Some may

want to evaluate their costs against

the WM/Refinitiv 4pm fixing plus

or minus a spread because that is

what is written into their investment

mandates.”

In this scenario, TCA helps identify

when and why a trade didn’t meet

that criteria.

ANALYSIS CONTRIBUTES TO

STRATEGY

TCA has evolved significantly from

post-trade reviews to becoming an

integral part of pre-trade and realtime

analytics, empowering traders

with proactive execution optimisation

strategies explains Stead.

“Predictive analytics enable traders to

forecast transaction costs and choose

optimal execution methods before

trading, while real-time TCA alerts

allow immediate strategic adjustments

to changing market conditions,” he

says.

“By integrating execution logic

directly within analytics, our

platform enhances traders’ ability to

respond dynamically during trades,

substantially improving outcomes

such as reduced slippage and market

impact.”

TCA has evolved to become an integral part of pre-trade and real-time analytics

While early TCA efforts were often

regulatory box-ticking exercises,

today’s advanced frameworks feed

directly into pre-trade decision making.

But this evolution comes with a caveat:

accuracy is now non-negotiable.

“Furthermore, pre-trade tools only

add value if they understand the

42 MAY 2025 e-FOREX


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MAY 2025 e-FOREX 43


TRADING OPERATIONS

Integrating Transaction Cost Analysis into FX trading workflows

“Regulators will want proof that execution policies are not

only documented but demonstrated, which means showing

how TCA results feed back into execution decisions and

counterparty reviews.”

Paul Lambert

underlying volatility in the market at

the time,” says Lambert. “We have

developed an expected spread model

that calculates the volatility in the

market over the preceding five minutes

and adjusts the spreads accordingly.

This is useful in the post-trade TCA

process as well, as it helps clients

understand when costs have risen due

to market volatility.”

In terms of implementation, BestX

has focused on the areas where it can

get the cleanest and most sanitised

dataset, spending the majority of its

time working with platforms, order

management systems, custodians and

banks to ensure data consistency.

“If a client trades on Bloomberg, for

example, we will get their files directly

and because it’s all cloud-based and

the install is just a Chrome-based

browser, they are ready to go,” says

Nurbhai. “The training is more around

how to utilise the tool to get the most

out of it.”

WELL WORTH THE COST

As for how to measure the cost

effectiveness of TCA, he says he has

spoken to firms who say they have

made savings that outweigh the

cost of a licence by being able to

identify trades that were erroneously

booked.

“They are also able to evaluate

their counterparties in an empirical,

quantitative manner,” adds Nurbhai.

“As these counterparties are trying

to improve their performance to gain

a greater share of trading activity,

this also leads to cost savings. Outlier

detection drives value by improving

counterparty competitiveness.”

Effective TCA implementation

requires meticulous data

management, justified benchmark

selection, comprehensive

documentation and independent

verification to meet stringent

regulatory requirements such

as MiFID II and FX Global Code

adherence. Leveraging platforms

with robust governance, audit and

reporting functionalities is critical.

“Trading firms can evaluate TCA costeffectiveness

by establishing clear

execution cost baselines, accurately

measuring investments in TCA

technology and consistently tracking

improvements post-implementation,”

says Stead. “Translating reduced

slippage and lower market impact

into monetary terms relative to

trading volume demonstrates

tangible benefits.”

Scalability and adaptability in TCA

require adopting flexible, modular

infrastructures capable of handling

increased data volumes and market

evolution.

“Leveraging AI-driven analytics

enhances dynamic responsiveness

to changing market conditions,”

observes Stead. “Integrating these

systems seamlessly requires careful

planning, including phased rollouts

and interoperable design using

standard protocols.”

Buy-side firms under pressure to accomplish more with fewer resources have limited bandwidth for

trying new trading tools

Effective integration depends on

flexibility and interoperability. TCA

systems must be able to plug into

existing trade management systems,

OMS platforms and data lakes

without disruption.

44 MAY 2025 e-FOREX


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MAY 2025 e-FOREX 45


TRADING OPERATIONS

Integrating Transaction Cost Analysis into FX trading workflows

“TCA can also be used to show the best performing algos

historically based on fill speed and spread, helping clients

decide whether to trade RFQ or algo,”

Yusuf Nurbhai

DON’T UNDERESTIMATE

REGULATORY REQUIREMENTS

Regulators are increasingly wary

of conflicted benchmarks - using

timestamps that are off by even

hundreds of milliseconds is akin to

flying blind and firms need to apply

TCA methodology consistently across

trades and be able to explain their

logic months later in an audit or client

review.

“Many desks focus on spot FX but

regulators expect the same best

execution standards for forwards and

THE FUTURE OF

FX TCA POINTS

TOWARDS GREATER

INTEGRATION

WITH PREDICTIVE

ANALYTICS AND AI

swaps,” says Lambert. “They will want

proof that execution policies are not only

documented but also demonstrated,

which means showing how TCA results

feed back into execution decisions and

counterparty reviews.”

Legacy TCA systems were often built

for static, low frequency analysis

and don’t scale well. New Change

FX rebuilt its TCA platform from

the ground up using a cloud-native

architecture, which allows the system

to scale horizontally and vertically

without compromising performance or

user experience.

“The platform automatically consumes

client execution data, matches it

against high frequency benchmark

data and delivers both post- and pretrade

insights via API or dashboard,”

explains Lambert. “This scalability

makes the system future-proof,

capable of adapting to the evolving

dynamics of global FX markets.”

Crouch explains that when it comes

to achieving seamless integration

with existing systems, Ideal utilises

proprietary, automated tools to

minimise client effort, making the

integration process as effortless as

possible. “Our tools normalise the data

from internal systems and vendors -

we typically get clients live in days or

weeks,” he says.

Buy-side firms under pressure to

accomplish more with fewer resources

have limited bandwidth for trying new

trading tools. When they start doing

TCA in-house, they often need to

source new data, requiring technical

work and budget.

“If we look at where best execution

started, the only way you can

show you are doing a good job

is by getting data from loads of

counterparties - and sourcing that

data is a complicated process,” says

Crouch. “Contractually, some of these

providers don’t want to give data to

other firms. In this scenario, a third

party can play a valuable role by

showing firms where they sit in the

broader market ecosystem without

disclosing sensitive information.”

THE POWER OF DATA

The impartiality of the data used

to produce TCA reports has been a

contentious topic in the FX market

for some time. However, Crouch says

reporting has become much more

transparent over the last decade.

“At this point, showing inaccurate

analysis would require malicious intent

and I just don’t think any platform

would do that,” he says. “That said,

the benefits of full independence are

focus and flexibility. Independence

allows us to utilise data from many

sources to produce a more complete

assessment.”

Crouch also emphasises the

importance of data privacy. “We keep

our data fully segregated, whereas

46 MAY 2025 e-FOREX


TRADING OPERATIONS

other firms co-mingle data for peer

analysis,” he adds. “The extent to

which an analytics firm is keeping a

user’s data completely private drives

many client decisions. Firms seek Ideal

solely because we safeguard their

privacy.”

“People in the Middle East are becoming more aware of FX

trading, and they now have access to easy-to-use apps, AIpowered

tools, and social trading platforms.”

opportunities to perform better by

trading on other venues.

Lambert suggests the most important

question in TCA is deceptively simple

(what are your trades being measured

against?) and adds that venueprovided

TCA reports often benchmark

execution against the provider’s own

prices, offering only a narrow view of

performance.

“As an independent provider, we

benchmark trades against a marketwide,

regulated data set. This

objectivity provides a clear, unbiased

view of execution quality across the

full FX landscape, meaning firms can

be confident they are performing well

relative to the best available market

conditions.”

Venue-provided TCA reports often

carry inherent conflicts of interest,

risking biased benchmarks and

selective data representation,

says Stead. Independent TCA

providers counteract these issues by

delivering impartial, comprehensive

data analyses using standardised

methodologies.

smartTrade complements

independent analysis by offering

transparent, impartial benchmarking

tools, supported by its flat-fee model,

ensuring that data used for TCA

remains clean and unbiased.

As clients increasingly trade across

multiple venues, aggregating TCA

reports across venues to get a holistic

view of trading performance becomes

very difficult – and if they are only

evaluating performance based on

the available market data of an

individual venue, they may be missing

“The buy-side can also opt to have

their data aggregated, anonymised

and put into a community data pool

to allow them to evaluate their trading

performance against their peers,” says

Nurbhai. “So you can see the value of

data based on verified trades rather

than trades that have been handpicked

by a venue or a liquidity provider.”

INTEGRATION THE WAY

FORWARD

The future of FX TCA points towards

greater integration with predictive

analytics and AI, providing real-time

insights and hyper-personalised

execution strategies across asset

classes. Future-oriented TCA systems

will dynamically adapt trading

strategies mid-execution and provide

deeper analytical insights into liquidity

provider behaviours and algorithm

performance.

“We are leading this evolution by

integrating advanced AI tools such

as Copilot into trading workflows,

leveraging modular microservices

and customisable APIs to ensure

continuous adaptation to market

trends, ultimately delivering enhanced

execution intelligence and superior

operational effectiveness,” adds Stead.

According to Nurbhai, the ‘sand in the

gears’ of TCA is when a busy buy-side

trader has to log into multiple systems

to get trading information before

going back into their OMS or EMS,

which is why his firm created a tool

that will interrogate its database to

provide a ranking of counterparties.

“TCA can also be used to show the

best performing algos historically

John Stead

based on fill speed and spread,

helping clients decide whether to

trade RFQ or algo,” he says.

Crouch emphasises the importance

of being able to assist firms as they

trade a wider range of asset classes,

utilising asset agnostic analysis and

addressing nuances of each asset

class.

“Ideal focuses on automation,

enabling users to understand the

variables that drive profitability and

risk - that simplified process saves

time across management, risk, sales,

and trading teams,” he says.

Lambert reckons the future is live

TCA with immediate feedback loops,

informing pre-trade analytics such

as the cheapest date to roll a swap

to, because the future of trading is

already here with machines trading

with machines.

“The future will be about realtime,

machine-readable live TCA,

not reports at T+1,” he says. “We

are talking live analytics that plug

directly into automated execution

engines, enabling adaptive behaviour

on the fly.”

MAY 2025 e-FOREX 47


How LSEG helped a multinational

corporation automate its treasury

workflows to optimise risk

management and FX trading

By collaborating with LSEG FX, Mondelez International has been able to

simplify workflows, access more FX liquidity and improve the efficiency

of its treasury function

CASE STUDY

Mondelez International Inc. is an

American multinational confectionery,

food, holding, beverage and snack

company headquartered in Chicago.

One of the largest companies of its

kind in the world, Mondelez had

annual net revenues in 2024 of

approximately $36 billion. Mondelez

has operations in around 80 countries.

Mondelez’s treasury has become a

leader in FX workflow automation,

maximising efficiency while enabling

the team to change focus from simply

managing transactions to optimising

risk management. Mondelez initially

built a complete risk management

framework, which was designed to

respond quickly to market conditions.

FXall plays a key role in this integrated

framework.

BUSINESS CHALLENGE

Companies looking to thrive in

competitive markets are continually

challenged by factors such as market

volatility, economic and geopolitical

uncertainty and the cost of hedging and

trading. A lack of pricing transparency

in certain currency regions, along with

high hedging costs for longer maturities,

can put multinational businesses at a

disadvantage.

As a growing company operating in

multiple markets, Mondelez needed an

efficient, reliable, comprehensive and

scalable treasury function, where high

levels of automation accelerate and

simplify end-to-end workflows, improve

performance and cut costs.

Workflow automation is an important

Companies looking to thrive in competitive markets are continually challenged by factors such as

market volatility, economic and geopolitical uncertainty and the cost of hedging and trading

way for the company to become more

efficient, while accurate and reliable

data is vital for forecasting and effective

risk management strategies, which

include the utilisation of FX options.

Lyubomir Apostolov, Regional Head of

FX at LSEG in Zurich, said, “In the last

few years, we observe an increasing

reliance on FX option strategies

amongst corporations as this client

segment seeks greater flexibility in risk

management and a more cost-efficient

hedging alternative to traditional

instruments like FX Forwards.”

SOLUTION

LSEG’s FXall was chosen so that

Mondelez could:

• Access a wide range of liquidity

providers, including specialist

emerging market FX options

providers, across the large number

of G20 and emerging market

currencies they trade, to meet their

liquidity needs

• Ensure seamless integration with

the company’s existing Treasury

Management System, improving

price transparency, increasing

efficiency in the team and achieving

cost savings

• Implement an effective FX options

hedging programme at scale while

enabling the treasury team to

efficiently manage its FX options

portfolio on a daily basis

48 MAY 2025 e-FOREX


CASE STUDY

WHY LSEG FX?

LSEG FX offered Mondelez a genuine

collaboration, maintaining an open

dialogue on the development of an

advanced trading workflow suitable

for Mondelez and other large

corporations.

ACCESS TO LIQUIDITY

The depth of liquidity, range of

supported currencies, and the variety

of liquidity providers were amongst the

key reasons why Mondelez International

chose to collaborate with FXall.

Access to emerging market FX options

liquidity was also an essential factor.

This reflects the global footprint of

Mondelez, with currency exposure in

most of the 80 markets in which it

operates.

EASE OF INTEGRATION AND AN

END-TO-END WORKFLOW

Mondelez and FXall established a

robust, scalable and flexible interface

allowing seamless order upload from

Mondelez’ Treasury Management

System (TMS) into FXall for execution.

An end-to-end workflow

implementation ensures not only

a direct trade download back into

the TMS, but also an automatic

trade confirmation with Mondelez’

relationship banks through FXall’s

Settlement Center. It was critical

that all systems aligned so that all

transactions go through Mondelez’

TMS to ensure maximum efficiency

and visibility.

“In the last few years, we observe an increasing reliance on FX

option strategies amongst corporations as this client segment

seeks greater flexibility in risk management and a more costefficient

hedging alternative..”

integrated tool which allows netting,

defining target premium or solving for

strike and trading FX options strategies

with or without delta hedge.

This tool has allowed Mondelez to

automate its FX options execution,

giving the global treasury team an

innovative capability to manage a

large and complex FX options portfolio

daily. LSEG continues to work in close

co-operation with the team to provide

additional enhancements and ensure

that the FX options pricing and trading

functions meet customer needs.

Adam Jarawka, Director Treasury

Operations at Mondelez International

in Zurich, said, “Our risk management

framework and high levels of

workflow automation have allowed us

to increase the volume of FX options

tenfold. This would not be possible if

trading was still manual.”

THE BENEFITS

The high level of automation which

FXall has brought to the Mondelez

treasury operation has largely

Lyubomir Apostolov

eliminated the use of spreadsheets

and time-consuming manual

processes, freeing the treasury team

to concentrate on other, higher value

tasks. Without automation, it would

be impossible for the relatively small

team to execute the desired volume of

trades.

By implementing FXall, Mondelez

has seen better and more consistent

pricing as well as a wider range of

liquidity providers to choose from,

which is particularly important in

emerging market currencies.

FX OPTIONS

With FX options recognised as offering

greater flexibility in terms of risk

management, Mondelez took the

strategic decision to implement a

comprehensive FX options programme

involving daily executions through FXall.

The options pricing and trading tool

was one of the key reasons why FXall

was selected. Options Pricer is an

Mondelez’s treasury has become a leader in FX workflow automation, maximising efficiency while

enabling the team to change focus from simply managing transactions to optimising risk management

MAY 2025 e-FOREX 49


How LSEG helped a multinational corporation automate its treasury workflows to optimise risk management and FX trading

“Our risk management framework and high levels of workflow

automation have allowed us to increase the volume of FX

options tenfold. This would not be possible if trading was still

manual.”

to refine its ‘best practice’ risk

management framework. In parallel

the company works together with

LSEG to benefit from increased

visibility across all assets, e.g. in

the area of commodities, and it is

exploring possibilities of adding

AI components to the framework

in order to identify trends more

efficiently and further automate the

processes.

The most recent milestone of the

collaboration between Mondelez

and LSEG has been the successful

implementation of FXall’s Settlement

Center, which enables FX options

trade confirmation via SWIFT Network,

premium netting and intelligent

matching criteria, recognising the

economics of different FX options.

The company’s ultimate goal is

the implementation of a single

LSEG platform which will link with

Mondelez’ TMS and include LSEG

Workspace, risk valuations, options

calculator, trade monitoring, execution

and pre- and post-trade TCA.

Adam Jarawka

CASE STUDY

Automation of processes brings

time-saving benefits and reductions in

the likelihood of human error. Where

errors do occur, the team has the time

and ability to identify any manual

trades and evaluate the cause of the

error and the solution going forward.

Increased transparency along with more

frequent and accurate valuations are

additional benefits. Mondelez confirms

that risk reporting and analytics have

improved significantly, with automated

ABOUT LSEG FXALL

FXall is a completely flexible

trading platform that gives you

seamless access to rich data and

smart tools.

With liquidity access, to straightthrough-processing,

FXall provides

the choice, agility, efficiency and

confidence you want. Trading

spot, forwards, swaps, NDFs and

options is only a click away.

Seamlessly execute your trading

strategies by leveraging fixing

orders, algorithmic and resting

orders, order splitting and utilising

send details to book off-platform

trades and receive full STP.

Multiple regulated venues in

one platform enable traders to

confidently comply with Dodd-

Frank, MiFID and other global and

local regulations.

statistics allowing the treasury team to

measure their performance and more

easily revise plans.

The increased market transparency

offered by FXall allows Mondelez to

focus on managing overall risk rather

than simply managing transactions,

increasing efficiency and benefiting

the company as a whole.

LOOKING FORWARD

LSEG and Mondelez International

are working together to create an

industry-leading automated FX trading

service for corporate treasuries.

With a goal of 95% FX transaction

automation, Mondelez is continuing

ABOUT MONDELEZ

INTERNATIONAL

Mondelz International empowers

people to snack right in over

150 countries around the world.

It operates with iconic global

and local brands such as Oreo,

Ritz, LU, Clif Bar and Tate’s Bake

Shop biscuits and baked snacks,

as well as Cadbury Dairy Milk,

Milka and Toblerone chocolate.

It is one of the largest snack

companies in the world with global

net revenues of approximately

$36 billion in 2024. It holds the

#1 global position in biscuits

(cookies and crackers) and #2

in chocolate, while it’s growing

rapidly in baked snacks. It also

makes and sells gum & candy as

well as various cheese & grocery

and powdered beverage products

in certain markets.

It has operations in more than

80 countries and employs

approximately 91,000 diverse and

talented employees in its factories,

offices, research & development

facilities and distribution activities

around the world.

50 MAY 2025 e-FOREX


The world’s

markets, your way

Service available only to Professional clients and varies per jurisdiction

Trading involves significant risk of loss

www.finalto.com

Scan to find out

more.

MAY 2025 e-FOREX 51


Build versus Buy:

Key considerations for financial institutions looking to capture

the benefits of further e-FX and digital transformation

Olli Lämsä, Head of FX Product Development/Product Manager at TreasurUp discusses some of the

operational, strategic, regulatory and technical issues that banks and financial institutions should

consider before deciding whether to build or outsource their e-FX and fintech requirements.

ASK A PROVIDER

Olli Lämsä

What are some of the main cost

considerations facing financial

institutions when looking into the

relative merits of whether to build or

buy financial technology?

Building in-house solutions requires

substantial investment in development

resources, specialized talent, and

infrastructure. Beyond initial costs,

banks face ongoing maintenance

expenses, security updates, and

continuous feature evolution. These

often make the total cost of ownership

significantly higher than projected.

A specialized fintech partner like

TreasurUp distributes development

costs across multiple clients, allowing

for continuous improvement while

keeping costs predictable. This enables

banks to access enterprise-grade

technology that would be prohibitively

expensive to develop individually.

In what ways can the speed of

market entry differ between building

and buying financial technology?

Developing a client-facing FX hedging

solution in-house typically requires 12 to

24 months, from initial concept to full

deployment. This period includes solution

architecture, software development,

integration with internal pricing and

trading engines, comprehensive security

testing, and regulatory compliance.

It also demands a dedicated, crossfunctional

development team to handle

the technical complexity and operational

requirements of the project.

In contrast, TreasurUp can deliver a fully

white-labeled FX solution within just

3 months. This significant reduction in

time-to-market provides banks with

a competitive advantage, enabling

them to respond rapidly to client

demand and market opportunities.

With minimal integration required into

existing systems, the platform allows

banks to begin capturing market share

while competitors may still be in early

development stages.

Meeting regulatory requirements is

critical for financial institutions. How

might this impact the decision to

outsource fintech functions and does

it necessarily present any hurdles?

Regulation is constantly evolving,

particularly around data protection

and transaction reporting. While this

raises legitimate outsourcing concerns,

mature fintech solutions are built with

compliance at their core.

TreasurUp’s platform addresses key

regulatory areas including data security,

audit trails, and regional requirements

like MiFID II. Specialized providers

can adapt more quickly to regulatory

changes by leveraging experience across

multiple implementations.

What sort of risk management

procedures and processes, for

example robust business continuity

and disaster recovery plans, should

financial institutions expect from

their fintech partners to ensure

the operational resilience and

performance of outsourced services?

Banks should expect fintech providers

to meet or exceed their own resilience

standards. This includes high uptime

SLAs, comprehensive disaster recovery

protocols and 24/7 monitoring. Recovery

time and point objectives should be

clearly defined and regularly tested.

Certifications like ISO 27001

demonstrate structured information

security management with documented

incident response procedures. Regular

reporting allows banks to maintain

appropriate oversight while delegating

the technical execution of resilience

measures.

52 MAY 2025 e-FOREX


ASK A PROVIDER

How do vendor fintech solutions

compare to internally developed

systems in terms of scalability?

Vendor solutions should be

architected for scalability from

the ground up. A modern cloudbased

platform like TreasurUp’s is

designed to scale across diverse client

segments, geographic locations, and

legal entities. It can efficiently handle

a high number of trades during

periods of market volatility and

supports the seamless integration of

new features without requiring major

system overhauls.

In-house systems, especially those

hosted on-premise, often face

infrastructure limitations requiring

costly upgrades to scale. Cloud-based

setups offer elasticity to handle peak

loads efficiently, delivering consistent

performance regardless of market

conditions-a critical advantage in

volatile FX markets.

How flexible can outsourced fintech

services be for those institutions

looking for solutions that can align

more perfectly with their strategic

business objectives and unique

needs?

Flexibility varies significantly between

providers. Some offer standardized

solutions, while others build

adaptability into their core offering.

Banks should seek partners willing

to tailor user experiences, branding,

workflows, and product roadmaps to

align with strategic objectives.

TreasurUp’s approach focuses on

configurability allowing banks to

maintain unique market positioning

while leveraging proven technology.

For financial institutions that decide

to go down the outsourcing route

what levels of customer service

should they expect from their

fintech providers?

Outsourced solutions enable banks to

rapidly deploy market-tested features

without the development cycle. These

capabilities often emerge from crossclient

insights, allowing banks to

benefit from collective learning.

TreasurUp regularly introduces

innovations like advanced risk

analytics or automated hedging

strategies that banks can quickly offer

to clients. We also explore emerging

technologies like stablecoins and

AI-based behaviour analysis,

inviting bank partners to test early

versions with selected clients. This

approach allows evaluation of

new opportunities with minimal

investment, accelerating response to

evolving client needs.

What factors and technical

considerations are important for

financial institutions in the choice

of suitable fintech provider for

them to partner with?

Some banks and financial

institutions remain concerned

about the data security and

integration issues associated with

outsourcing fintech. Should they

be?

Yes, these concerns deserve serious

consideration. Fintech providers must

demonstrate robust safeguards for

sensitive data throughout its lifecycle,

including encryption, access controls,

client data segregation, and incident

response capabilities. Independent

certifications provide third-party

validation of security measures.

Beyond security, TreasurUp has

established connectivity with major

bank systems and FX pricing engines,

ensuring secure data flow. The

right provider offers both technical

security and operational transparency,

allowing banks to maintain oversight

while gaining specialized expertise.

Banks should expect comprehensive

service beyond basic support.

This includes defined SLAs with

guaranteed response times, dedicated

success managers who understand

both the technology and business

objectives, and structured onboarding

with appropriate training.

The relationship should evolve

through regular strategic reviews

where both sides collaborate on

enhancements aligned with the

bank’s goals. TreasurUp’s model

includes proactive monitoring to

identify potential issues before they

impact service, ensuring the platform

continues to deliver measurable

value.

In what ways can outsourced

e-FX and white labelled fintech

solutions help banks and financial

institutions to more quickly capture

new business opportunities?

When selecting a fintech partner,

banks should prioritize:

• Proven track record with similar

institutions

• Seamless integration with existing

FX infrastructure

• Recognized security certifications

(ISO 27001)

• Regular platform updates and clear

technology roadmap

• Co-development aligned with bank

strategy

• Customization options preserving

brand identity

• Scalability for growth and new

features

TreasurUp meets these criteria

through our purpose-built FX

platform serving nine banks and

thousands of corporate users. Our

collaborative approach helps banks

compete effectively while maintaining

control of client relationships.

MAY 2025 e-FOREX 53


How Electronic Money

Institutions are promoting

financial inclusion

By Lissele Pratt, founder of Capitalixe

That’s daily life for over 1.4 billion

people around the world. They work,

they earn, they spend, but they’re left

out of the financial systems that many

of us rely on every day.

The traditional banking model hasn’t

been able to reach them. So, they’re

excluded.

this article, we’ll explore what EMIs

are, how they work, and how they’re

helping people take their first real step

into the financial system.

WHAT ARE EMIS?

An EMI is a licensed institution that

issues electronic money, a digital

form of currency that acts as an

But over the last few years, something

alternative to cash. When you make

has started to shift. A new wave of

a payment through a mobile wallet

digital-first financial institutions is

or load funds onto a prepaid card,

FINTECH

LISSELE PRATT

Imagine living without a bank account.

No safe way to save money. No simple

way to receive a payment. No access to

credit or a loan when you need it.

opening doors that were once closed.

They’re called Electronic Money

Institutions - or EMIs.

EMIs aren’t trying to fix the old system.

They’re building something different.

Faster. Simpler. More accessible. In

you’re using electronic money. It’s not

cryptocurrency. It’s real money, held

in digital form. When you top up an

e-wallet or use a prepaid card, that’s

electronic money in action.

HOW DO THEY WORK?

The process is really straightforward.

An EMI takes money from a customer

and stores it electronically, letting

that money be used for payments,

transfers, and transactions, often in

real-time, and typically at a lower cost

than traditional banks.

EMIs don’t offer loans or hold your

savings like a bank. Instead, they focus

on helping people and businesses

move money quickly, safely, and with

fewer barriers. Think online payments,

mobile wallets, cross-border transfers,

and financial tools for freelancers or

small businesses. That’s their world.

EMIs aren’t trying to fix the old system. They’re building something different

Because EMIs are built on modern

technology, they’re often faster, more

flexible, and cheaper to run than

traditional banks. And that makes

them especially powerful in places or

54 MAY 2025 e-FOREX


FINTECH

communities where banking access

has always been limited.

HOW ARE EMIS USING

TECHNOLOGY TO DRIVE

CHANGE?

When we talk about EMIs, we’re not

just talking about digital wallets or

mobile apps. We’re talking about how

they’re using cutting-edge technology

to completely reshape the way we

handle money:

Real-time transactions:

We live in a world of instant

messaging, instant streaming, instant

everything. So why are some banks

still making us wait between 1-5 days

to move money?

EMIs said: “That’s not good enough.”

Those same transactions don’t take

days with these institutions, but

seconds. They’ve designed systems

that make instant payments possible,

even if you’re sending to a completely

different country or continent.

They’re now also embedding instant

payment infrastructure to meet bold

regulatory mandates, like the EU’s

requirement that all banks offer SEPA

Instant transfers. That means moving

up to €100,000, across borders, in

seconds, not hours, not days.

Open banking:

But speed alone isn’t the revolution.

Open Banking is. Instead of locking

your financial data behind walls, Open

EMIs focus on helping people and businesses move money quickly, safely, and with fewer barriers

Banking gives you control. Want to phone to speak the same language

use your banking data to get a better and connect seamlessly with each

mortgage deal? Done. Want to track other, APIs make that happen.This

your spending across multiple apps? means faster innovation. Better

Easy.

features. And systems that work

together, not against each other. Think

With Open Banking, EMIs are tearing Lego blocks. You can build anything

down the walls that traditional banks when they fit together.

spent decades building. Like Tim

Berners-Lee said, “Data is a precious Biometrics and enhanced security:

thing and will last longer than the Speed means nothing without security.

systems themselves.” Open Banking And that’s where EMIs shine. They’re

gives that power back to the people. using biometric authentication (things

Back to you.

like fingerprints, face scans, even voice

recognition) as digital shields.

API integration:

How do EMIs make it all work

Passwords can be guessed. Biometrics,

together? Think of APIs as translators. they’re you. And no one can copy

They let apps and systems talk to each that. Some EMIs even use behavioural

other.

biometrics - like how you type, or how

you hold your phone - to detect fraud.

If you want your budgeting app, your Add in advanced encryption, multifactor

authentication, and EMI, your crypto wallet, and your

real-time

With Open Banking, EMIs are tearing down the walls that traditional banks spent decades building

MAY 2025 e-FOREX 55


How Electronic Money Institutions are promoting financial inclusion

you simply lived in the wrong place,

you were excluded. Financial services

became a privilege. Not a right. EMIs

are innovating and including.

Here’s how:

Mobile-first approach – reaching the

unreachable:

The average smartphone today has

more computing power than the

machines that sent us to the moon.

But what’s even more powerful is

what EMIs are doing with that power.

They’re turning smartphones into bank

branches. You don’t need to walk into

a building.

FINTECH

fraud detection, and what you get is

trust, built into the system.

Safety doesn’t stop at technology

either. EMIs operate under some of the

toughest regulatory frameworks out

there. They follow strict Anti-Money

Laundering (AML) laws.They meet

Know Your Customer (KYC) standards,

not just once, but continuously. They

use digital onboarding, AI-powered

EMIs use biometric authentication as digital shields

identity verification, and continuous

monitoring tools to stay compliant,

secure, and efficient. It’s the kind of

compliance that speeds trust up.

HOW ARE EMIS PROMOTING

FINANCIAL INCLUSION?

Let’s be honest. Traditional banking

left too many people behind. If you

didn’t have a credit history, a stable

income, a permanent address, or if

You don’t need payslips, paperwork,

or proof of address. You just need a

phone, and a connection. And that

simple shift is transforming lives.

For instance, in Africa digital wallets

powered by EMIs have given millions

access to send, save, and receive

money, sometimes for the first time

ever. Take OPay in Nigeria, for instance.

With 35 million registered users, it

supports SMS-based and app-based

payments, even on basic phones.

That’s critical in a country where 26%

of adults remain unbanked.

Another example is M-Pesa which is

the dominant mobile money service

in Kenya and a global benchmark for

mobile-first financial inclusion. It allows

users to deposit, withdraw, transfer

money, pay bills, and access microloans,

all via mobile phones-even basic ones.

M-Pesa’s reach extends to neighboring

countries, with over 50 million users

and a significant share of Kenya’s GDP

flowing through its platform.

EMIs operate under some of the toughest regulatory frameworks out there

Onboarding the underserved with

frictionless KYC:

Traditional banks often turn away

people who can’t tick every box -

utility bills, photo ID, proof of address.

EMIs are flipping that model.

56 MAY 2025 e-FOREX


MAY 2025 e-FOREX 57


How Electronic Money Institutions are promoting financial inclusion

FINTECH

Source: Vodafone

They use digital KYC tools like identity

checks through selfies, e-signatures,

and document scanning powered by

AI. In just minutes, a street vendor, a

gig worker or a refugee can get access

to a digital wallet, a virtual card,

even a multi-currency IBAN, turning

bureaucracy into possibility.

Some key innovations in this space

include:

• Selfie verification: Some platforms

use facial recognition to match

a live selfie with an uploaded ID

document. It takes seconds.

• Document scanning: Advanced

OCR (Optical Character

Recognition) extracts data from ID

cards and passports in real time. AI

checks for holograms, watermarks,

and microtext to detect fakes,

ensuring fast onboarding without

compromising compliance.

• Liveness detection: Some tools

go a step further, blocking spoof

attacks and deepfakes using NIST

Level 2 anti-spoofing technology.

That means only a real, live human

- not a photo or video - can

complete registration. This is now

used in digital onboarding flows

across emerging markets and by

global EMIs expanding into risksensitive

sectors.

Cross-border finance – sending

money, not losing it:

Now imagine this: You work hard

M-Pesa is a global benchmark for mobile-first financial inclusion

abroad. You send money back home.

But fees eat into your wages. Transfers

take days. EMIs saw that and realised

that it could be improved.

Today, they’re offering low-cost, nearinstant

cross-border payments. They’re

using SEPA instant transfers, local

payment rails, and crypto-fiat bridges

to make sure money arrives faster,

and stays intact.Because when you’re

supporting family back home, every

second matters. Every cent matters.

Financial literacy tools – not just

access, but understanding:

Access without understanding is not

empowerment. That’s noise. That’s

why many EMIs go further, offering

spending analytics, budgeting tips,

and savings nudges built right into

their apps. They’re gamifying good

money habits. They’re nudging users to

plan, not just spend.

They’re teaching, without preaching.

Because real inclusion means people

not only have money, but know how

to grow it.

WHAT CHALLENGES DO EMIS

FACE?

EMIs are pushing boundaries, but

they’re not without their own:

• Regulatory complexity: Unlike

traditional banks, EMIs must

navigate a patchwork of evolving

rules across borders. From PSD2

in the EU to local licensing in

emerging markets, compliance is

mandatory and it’s expensive.

• Trust and reputation: They don’t

hold banking licenses, and that

makes consumer trust harder to

win. One bad actor in the sector

can damage the perception of

them all. Building credibility

takes relentless transparency and

bulletproof security.

• Financial sustainability: Many

EMIs operate with razor-thin

margins. Balancing innovation

with profitability, all while keeping

services low-cost and inclusive,is

one of the hardest equations to

solve.

But here’s the point: Challenges don’t

stop change.They sharpen it. If EMIs

can overcome these hurdles, they

won’t just complement the banking

system but redefine it completely.

WHAT’S NEXT FOR EMIS – AND

WHY IT MATTERS

The story of EMIs isn’t just about

payments or technology. It’s about

possibility. Because when you give

someone the tools to save, to send, to

grow - what you’re really giving them

is power. Power to participate. Power

to plan. Power to build a future on

their own terms.

EMIs aren’t a perfect solution. But they

are a powerful one. They’re proof that

financial systems can be reimagined to

serve not just the few, but the many.

So the question isn’t if EMIs will shape

the future of finance. It’s how fast we

can support them to make that future

more inclusive, more transparent, and

more just.

And maybe one day soon, we’ll stop

calling it financial inclusion. Because

everyone will simply be included.

58 MAY 2025 e-FOREX


®

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60 MAY 2025 e-FOREX

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